The board of directors and management of Roundbank understand how important personal privacy is to our customers. In the interest of protecting the privacy of our customers the board is adopting this Privacy Policy.

Customer Expectations
We know that our customers expect privacy and security for their personal and financial affairs. We must take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. It is the policy of this bank to use customer information in a manner that protects the privacy of individual customer information, records and accounts.

Permissible Reasons to Collect and Maintain Information about Our Customers
We will collect, retain, and use information about our customers only where we believe it will help administer our business or provide products, services, and other opportunities to them. We must also collect certain information in order to comply with certain laws and regulations. We may use the information to create new products or improve existing products, services and delivery systems.

Types of Information We Collect
At Roundbank we collect nonpublic personal information from many sources. Nonpublic personal information does not include that which is available from government records, widely distributed media, or government-mandated disclosures.

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms
• Information about your transactions with us
• Information about your transactions with nonaffiliated third parties
• Information from a consumer reporting agency

We do not disclose any nonpublic personal information about you to anyone, except as authorized by law.

Limiting Employee Access to Information
We will implement procedures that limit employee access to individual customer information to those employees with a business reason to know such information about our customers. All department supervisors will inform employees about the importance of confidentiality and customer privacy through new employee orientation and ongoing departmental communications. Bank management is directed to take appropriate measures to enforce employee privacy responsibilities.

Bank management is directed to maintain security standards and procedures to help prevent unauthorized access to confidential information about customers. We will update and test the technology on an ongoing basis to ensure the protection and assure the integrity of our customer information.

Restrictions on Disclosing Information to Parties Outside Our Affiliated Banks and Companies

We will not reveal specific information about customer accounts or other personally identifiable data to parties outside our affiliated banks and companies for their independent use unless:

1. The customer requests or authorizes it.
2. The information is provided to help complete a transaction initiated by the customer.
3. The information is provided to a reputable credit bureau or similar information-reporting agency
4. The disclosure otherwise is lawfully permitted or required.

Restrictions on Disclosing Nonpublic Personal Information on Former Customers

We do not disclose nonpublic personal information about former customers, except as permitted by law.

If we change our policy or practice by, for example, adding a category of information we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt-out of the disclosure.

Maintaining Accurate Information

Roundbank is committed to maintaining accurate, current, and complete records. We have established policies and procedures to ensure that all requests to correct inaccurate information are responded to in a timely manner. If you receive information from the Bank that you believe to be inaccurate, or have any questions regarding our privacy policy, you should contact us immediately in writing or by phone.